State v. Angei
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The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and sentence, holding that, contrary to Defendant's arguments on appeal, the requirements of Haw. Rev. Stat. 327C-1 does not apply to all criminal cases involving death.
Defendant was charged with murder in the second degree. A jury found Defendant guilty of the lesser-included offense of manslaughter based on reckless conduct. The ICA affirmed. The Supreme Court affirmed, holding (1) a death determination under section 327C-1 was not required or implicated under the circumstances of this case because there was sufficient evidence for a reasonable juror to conclude that death was proven beyond a reasonable doubt; and (2) the circuit court did not err in failing to instruct the jury on the lesser-included offense of reckless endangering second.
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